New U.S. sanctions

PJSC Rosneft Oil Company and its subsidiaries and associates involved in oil production and refining: 

• JSC Kuibyshevskiy Oil Refinery, LLC RN Tuapse Oil Refinery, JSC Achinsk Refinery of Eastern Petroleum Company (JSC ANPZ VNK), JSC Ryazan Oil Refinery Company (AO RNPK), OJSC Novokuybyshevsk Refinery, LLC RN Komsomolskiy Refinery, LLC Taas Yuryakh Neftegazodobycha
• AO Sibneftegaz, CJSC Vankorneft, JSC Vostsibneftegaz, JSC Grozneftegaz, JSC Rospan International, JSC Samaraneftegaz, JSC RN Nyaganneftegaz, LLC Kharampurneftegaz, LLC Kynsko Chaselskoe Neftegaz, LLC RN Krasnodarneftegaz, LLC RN Purneftegaz, OJSC Orenburgneft, OJSC Samotlorneftegaz, OJSC Syzran Refinery, PJSC Verkhnechonskneftegaz (VCHNG), PJSC Saratov Oil Refinery, PAO Udmurtneft Imeni VI Kudinova (a joint venture between Rosneft and Sinopec), LLC RN Uvatneftegaz, LLC RN Yuganskneftegaz
• LLC Bashneft Dobycha, LLC Bashneft Polus

PJSC Lukoil and its subsidiaries (LLC Lukoil Perm, LLC Lukoil Aik, LLC Lukoil Kaliningradmorneft, Lukoil West Siberia Limited, LLC Russian Innovation Fuel and Energy Company (OOO RITEK)). LLC Uraloil (OGRN 1166313158439, located in Perm) was also included in the SDN List despite having discontinued its operations in summer 2025 after a merger with LLC Lukoil Perm.

General License 124A, “Authorizing Petroleum Services and Other Transactions Related to the Caspian Pipeline Consortium and Tengizchevroil Projects”[2]

Authorizes transactions with PJSC Lukoil and PJSC Rosneft Oil Company (as well as entities owned 50% or more by these companies) that are related to the Caspian Pipeline Consortium or Tengizchevroil projects.

Replaced and superseded General License 124 from 22 October 2025; the expiration date is not specified.

General License 126, “Authorizing the Wind Down of Transactions Involving Rosneft or Lukoil”[3]

Authorizes transactions with PJSC Lukoil and PJSC Rosneft Oil Company (as well as entities owned 50% or more by these companies) that are necessary to the wind down of any transaction with these entities, provided that any payments to them are made into special and segregated blocked accounts.

Expiration date – 21 November 2025.

General License 127, “Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Rosneft or Lukoil”[4]

Authorizes transactions that are ordinarily incident and necessary to the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity issued or guaranteed by PJSC Lukoil and PJSC Rosneft Oil Company (as well as entities owned 50% or more by these companies) to non-U.S. persons.

This general license does not authorize such transactions to U.S. persons.

The license also authorizes transactions that are ordinarily incident and necessary to facilitating, clearing, and settling trades of covered debt or equity of the abovementioned companies that were placed prior to 4:00 p.m. EDT, 22 October 2025.

It also authorizes transactions that are ordinarily incident and necessary to the wind down of derivative contracts that include PJSC Lukoil or PJSC Rosneft Oil Company (as well as entities owned 50% or more by them) as a counterparty or are linked to covered debt and/or equity of such companies, provided that any payments to them are made into special and segregated blocked accounts.

Expiration date – 21 November 2025.

General License 128, “Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia”[5]

Authorizes transactions that are ordinarily incident and necessary to the purchase of goods and services from, or the maintenance, operation, or wind down of Lukoil retail service stations located outside of the Russian Federation.

The license applies to retail service stations that meet all of the following criteria:

• Retail service stations located outside the Russian Federation and in existence on or before 22 October 2025 in which:
• PJSC Lukoil has an interest, or
• Any entity, in which Lukoil owns, directly or indirectly, a 50 percent or greater interest, has an interest

Any payment, directly or indirectly, to these companies (other than direct payments to retail service stations) is to be made into a special and segregated blocked account.

Expiration date – 21 November 2025.